For the second time in recent months, Delta's collection and use of its customers' data is coming under scrutiny.

In December, the State of California lodged a complaint against Delta for collecting personal information via its Fly Delta mobile app without notifying users that it was doing so.

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The latest kerfuffle began last week with a FlyerTalk thread, "Delta and new DL.com Profiles a Lot About You," begun by BallardFlyer on January 24.

The poster was intrigued to discover that when the new DL.com website launched on a user's computer, it displayed a link to a user profile that presumably allows the site to generate pages specifically tailored to the individual.

In addition to such expected information as SkyMiles number, elite tier, home airport, and the like, the profile includes a user's income, zip code, date of birth, amount spent on airfare, home value, type of credit card, children's age range, hotel brand preference, and more. (The profile obviously was never intended to be publicly viewable, and it can no longer be displayed.)

I was intrigued as well, and sent Delta a pointed query regarding the collection and use of customer information. A spokesperson responded as follows:

Like many companies, Delta uses demographic and other data to help provide a personalized experience for our customers, improve how we communicate with them and design offers customized to their interests. While the data displayed was only available to the specific user, we sincerely regret that this code displayed and the confusion it may have caused for our customers. We worked to resolve the issue promptly upon discovering it.

That didn't address the questions of how the data was collected or what it is being used for.

Delta's privacy policy includes a list of the types of data collected on the site—all of it auto-generated by the user's Internet browser or entered by the user himself in the normal course of making travel bookings.

There's no mention of income, home value or other such highly personal information that we now know is in fact being captured.

It can be deduced from the exposed user profiles that Delta is getting some of the non-airline data from its credit-card partner, American Express, and other information from Experian, a marketing-data company that builds demographic profiles of customers based on a combination of company-supplied information and its own proprietary databases.

Regarding the use of this fairly robust information, Delta's privacy policy advises that "We may use the information to design offers customized to your interests" and "We routinely share your information with our SkyMiles Partners and Promotional Partners and our subsidiaries including Delta Connection Carriers."

That's not very reassuring. Delta's promotional partners are, by definition, any company Delta happens to be doing business with.

As for Delta's use of the data, after viewing his own profile, poster Deltahater expressed a common theme among the FlyerTalk commenters, as follows:

Most large American companies do profiling. I have no problem with that. What I do have a problem with is that DL is saying they are using this for a "customized experience." Well, we all know the old adage "Garbage in, garbage out." It seems that in 30-50% of the cases the data was wildly inaccurate. That then leads to poorly customized experiences and DL markets to many of us in the wrong way or the wrong products. For example, I might be missing out on valuable deals that would be spot on for me, except DL has the wrong data and keeps sending me offers for ATL-SFO.
The concept is great, the execution is terrible. If I were VP of Marketing for DL, I'd cancel my Experian contract and get my money back.

Good Big Brother, Bad Big Brother

Delta could turn what threatens to become another P.R. black eye into a marketing win by being fully transparent about its data strategies and tactics and positing them as a plus for consumers. Spin it as personalization, not manipulation: "The website that's all about you."

Give users a sense that they're willing participants, not hoodwinked dupes. Give them a chance to review their profiles and correct any missing or incorrect information.

And provide an easy way for users to opt out of having their information collected and used. If the "personalized experience" is really such a consumer benefit, they'll want to opt back in after experiencing the impersonal alternative.

It's up to Delta to show that big brothers can be a force for good.

Reader Reality Check

Are you surprised at how much personal information Delta is collecting on its site visitors?